The National Futures Association (NFA) held a commodity pool operators (CPO)/commodity trading advisor (CTA) regulatory seminar in April to provide guidance to managers, so they understand what is expected of them and can prepare when the regulators come to check them out. While CTAs and CPOs are nor the target of new legislation, many who trade over-the-counter swaps would be affected, says Jon Grady, general counsel of Steben & Company. CPO participants who engage in swaps would have to be registered as investment advisors, says Grady. While NFA is required to audit all CTA/CPOs approximately every three years, they have a risk-based audit criteria that may call for more frequent audits. Some new areas of focus NFA is targeting involve valuation and side deals that managers sometimes give selected clients. While valuation is not a concern for managers who stick to exchange traded futures that are marked to market daily, it is a focus for anyone trading more exotic instruments.